Transfer Pricing Recharacterisation – Exploring the unexplored aspects

It is always debated as whether the tax authorities in the garb of transfer pricing can obligate taxpayers to maximise their local profitability in hindsight…

Transfer Pricing Characterisation – Why does it matter? (Republished)

The risk-reward theory in economics states that higher the risk, higher the return. This principle of economics is also used in transfer pricing (TP) to determine the arm’s length compensation of the transacting parties.

Transfer Pricing Conference 2022

Ensure Greater Compliance with Transfer Pricing Regulations.

Transfer Pricing Guidance on COVID-19 Impact – Part 2

This article is a continuation of Part 1 covering guidance on the transfer pricing implications of the COVID-19 pandemic (the Guidance Note) issued by the Organisation for Economic Cooperation and Development (OECD).

Transfer Pricing Guidance on COVID-19 Impact – Part 1

On 18 December 2020, the Organisation for Economic Cooperation and Development (OECD) issued a guidance note on the transfer pricing implications of the COVID-19 pandemic (the Guidance Note).

Advance Pricing Agreement (APA): Ensuring Certainty in Uncertain Times

Transfer Pricing (TP) risk has never been as high for MNEs as it is today due to additional reporting requirements and exchange of information emanating from Base Erosion and Profit Shifting (BEPS) action plans issued by the Organisation for Economic Co-operation and Development (OECD).